Policies and Procedures

Code of Conduct:

CHF prescribes to a policy whereby employees must avoid strictly any conflict of interest or even the appearance of a conflict, and as such, employees would have no reluctance to full disclosure of their actions or relationships with perspective vendors, contractors, or consultants.

• No CHF employee shall be engaged in conduct resulting in a potential conflict of interest. Any employee is in a potential conflict of interest, when any action by CHF, whether isolated, recurring or continuous, is to the direct financial advantage of this employee, such employee's spouse, parent or child.
• No employee shall participate in the selection, final choice, or management of a contract, covered by donor funds if a real or apparent conflict of interest would be involved. Such a conflict of interest would arise when any employee or any member of his/her family, his/her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in the firm/organization selected for a final contract.
• CHF's employees shall neither solicit nor accept gratuities, favors, or anything of monetary value from contractors, sub-recipients or parties of project contractors.

As appropriate, either CHF Field Office Director or CHF/HQ senior management will be responsible for determining the disciplinary action that will be imposed for any code of conduct violations.

CHF Policy on Fraud:

We believe our greatest assets are our beneficiaries and the people who serve them. We are obligated to both, and to our organization to operate according to the highest standards of personal and corporate behavior.

• Definition: Fraud is an intentional act of deception, misrepresentation, impropriety, or concealment to gain something of value at the detriment of another.
• Types: Fraudulent acts can include forgery or alteration of any document or policy; falsifying time sheets or documents; abuse of sick time; theft; billing for services not performed and other irregular billing practices; inflating charges for services or products; false claims; and other improprieties.
• CHF is committed to complying with the laws and regulations, and will cooperate with appropriate law enforcement or regulatory agencies. All suspected potential fraud will be investigated and if appropriate, pursued for prosecution.
• Disciplinary action will include any of the following: warnings, suspension, sanctions, termination of employment or contracts, recommendation of any license revocation, recommendation of criminal prosecution, civil litigation and restitution.
• Fraud awareness training will be an ongoing process encouraged and supported by the organization so that the highest quality service at a reasonable cost can be provided to our customers.
• Field Finance Directors are responsible for knowing what types of fraud can occur and for being alert to symptoms of wrongdoing. Upon discovery of any potential wrongdoing, Finance Directors are responsible for immediately notifying the CHF country Directors and CHF Vice-President For Finance.
• Field Finance Directors should follow the “Fraud Review Checklist” once a year and report their conclusions to CHF’s Vice President of Finance. If there is no Field Finance Director, then the Country Program Director must carry out this assignment.

CHF Policy on Corruption:

It is the policy of CHF to adhere to the mandates of the Foreign Corrupt Practices Act, 15 U.S.C. 78dd-1, et seq (FCPA). Accordingly, CHF expects its employees agents, partners, and other representatives to operate in a fashion consistent with this law.

The FCPA forbids payments, favors, and offers of payment/favors to foreign officials, foreign political parties, or candidates for political office in a foreign country in order to gain any competitive advantage over other parties in the award of government business, licensing, or other exercise of government discretion.

Although there are exceptions to the coverage of the FCPA (e.g. so called “grease-payments” and payments permissible under the law of the country in which a CHF office operates), any payments, gift, or other transfer of an object or service of value with an eye toward influencing government decision making must first be presented to CHF’s legal counsel for authorization. Further, because the conduct of CHF’s partners and agents bears upon CHF’s liability under the FCPA, it is the responsibility of the CHF officer or employee engaging the services of a contractor or entering into a joint venture arrangement with a third party to inquire into the business practices of that entity to determine whether they make potentially illegal bribes in violation of the FCPA. Should it appear that the third-party entity engages in questionable practice notify CHF’s legal counsel for guidance.

In addition, once it is determined that a given payment, gift, or contract is permissibly under the FCPA, it is crucial that CHF document the fact of the payment/gift/contract, the purposes of the payment/gift/contract, and the due diligence CHF exercised prior to consummating that payment/gift/contract. It is therefore incumbent upon every CHF employee to comply with CHF accounting policies and internal control procedures even when the proposed payment/gift/contract is deemed proper under the FCPA.

In short, it is the duty of every CHF employee, agent, partner, or representative to:

• Comply with CHF procedures and the laws of the United States and the foreign country in which CHF conducts business;
• Refrain from making any corrupt payment, regardless of amount, to foreign government or political party officials either directly or indirectly;
• Refrain from using CHF assets for any illegal or unethical purpose;
• Refrain from creating or maintaining secret funds or assets for any purpose;
• Adhere to CHF accounting politices and internal control procedures;
• Refrain from making false or misleading entries in CHF records or making any payment on behalf of CHF without adequate supporting documentation; and
• Report all violations of CHF financial and accounting policies to the Executive Office.